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Quality First Roofing, Inc. v. Cedar Valley Exteriors, Inc.

United States District Court, D. Nebraska

April 9, 2014

Quality First Roofing, Inc., a Nebraska corporation, Plaintiff/Counter Defendant,
v.
Cedar Valley Exteriors, Inc., a Minnesota corporation, Defendant/Counter-Cross Plaintiff,
v.
JOSE A. GONZALEZ, and CRISTIAN A. GONZALEZ, Cross-Defendants.

STIPULATED PROTECTIVE ORDER

CHERYL R. ZWART, Magistrate Judge.

Upon stipulation of the parties to the above action, pursuant to Fed.R.Civ.P. 26(c) that trade secret or financial information be disclosed only in designated ways:

1. As used in the Protective Order, these terms have the following meanings:

"Attorneys" means counsel of record;

"Confidential" documents are documents designated pursuant to paragraph 2;

"Confidential - Attorneys' Eyes Only" documents are the subset of Confidential documents designated pursuant to paragraph 5;

"Documents" are all materials within the scope of Fed.R.Civ.P. 34; "Written Assurance" means an executed document in the form attached as

Exhibit A.

2. By identifying a document "Confidential", a party may designate any document, including interrogatory responses, other discovery responses, or transcripts, that it in good faith contends to constitute or contain trade secret or financial information. To the extent only a portion of a document requires treatment as a Confidential document, the disclosing party shall designate only that portion of the document as confidential, and the receiving party may freely disclose the non-confidential portions of the document.

3. All Confidential documents, along with the information contained in the documents, shall be used solely for the purpose of this action, and no person receiving such documents shall, directly or indirectly, transfer, disclose, or communicate in any way the Confidential contents of the documents to any person other than those specified in paragraph 4. Prohibited purposes include, but are not limited to, use for competitive purposes or the prosecution of additional intellectual property rights.

4. Access to any Confidential document shall be limited to:

(a) the Court and its officers;

(b) Attorneys and their office associates, legal assistants, and stenographic ...


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